Commissioner of Income Tax (TDS), vs. M/s Country Club Inda Limited

234B of the Act and consequently, the same is not being considered. 35. The first three questions framed in the aforesaid appeals relate to the dispute whether the Assessee has a PE in India and the fourth question relates to the issue of attribution of income to the Assessee‘s alleged PE in India. ITA 666/2014 & Ors. Page

Commissioner of Income Tax, Guntur vs. Agricultural Market Committee, Sattenapalli

In the result, the order of the income tax appellate tribunal

Bench: GODA RAGHURAM,M.S.RAMACHANDRA RAO

234B and 234D of the Act on the facts and circumstances of the case? 2. Facts leading to filing of this appeal briefly stated are that the assessee is a private limited company engaged in the business of manufacture and 4 export of readymade garments. The assessee for the Assessment year 2008-09 filed the return of income declaring total

The Commissioner of Income tax vs. M/s. ragamayee bAr AND Restaurant,

The appeals stand dismissed

Bench: V.V.S.RAO,RAMESH RANGANATHAN

3. Whether case in question should have been dealt with in accordance with the requirement of Section 132B ibid and if it was not dealt with, by not taking note of said provision, whether a case for remand id made out for examining the question keeping in view the requirement of section 132B ibid”. 3.2 Appeal No. 216/2010 admitted

PR COMMR OF INCOME TAX-2, HYDERABAD vs. K RAVINDER REDDY, HYDERABAD

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

3) which deals with only fixed place PE. It is indeed correct that neither a dependent agent PE nor a fixed place PE can be constituted if the business activities undertaken are preparatory or auxiliary. However, Article 5(3) makes no mention of the authority to conclude contracts – language that is explicitly used in Article 5(4)(a). Accordingly, reading